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U.S. v. Furkin, No. 95-3911 (7th Cir.) (119 F.3d 1276) (July 14, 1997) (Judge William J. Bauer)

In approving the use of a sophisticated means enhancement under ยง 2T1.1(b)(2), the court agreed that "there is a certain amount of overlap among various factors as they relate to sophisticated means, obstruction of justice, departure, as well as the guideline for the underlying conspiracy. However, as the Government points ...

 

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